Privacy policy.

INNER SANCTUM SPORTS MANAGEMENT PRIVACY POLICY (VERSION 1)

Inner Sanctum Sports Management (ISSM) understands the importance of safeguarding Personal Information and is fully committed to respecting privacy rights. 

INTRODUCTION 

This Privacy Policy (Policy) outlines how ISSM deals with Personal Information, in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). ISSM, in accordance with the legal requirements, intends to update this Policy periodically.

Personal Information has the meaning given to it in the Privacy Act.

PROTECTION OF PERSONAL INFORMATION 

ISSM puts the highest priority on the safeguarding of Personal Information and is fully dedicated to treating it with utmost respect. 

By choosing to use ISSM’s services, you agree to the collection, disclosure, and use of your Personal Information according to this Policy. ISSM assures that it will not share your information with anyone except as described in this Policy.

WHAT PERSONAL AND SENSITIVE INFORMATION DOES ISSM COLLECT? 

Personal Information

ISSM collects, holds, and discloses Personal Information for various purposes and ensures that it is protected at all times. The Personal Information that ISSM collects varies depending on the situation, but ISSM collects only the Personal Information necessary for providing its services. Some information collected by ISSM consists of:

  • identity data (name, nationality, date of birth, gender)

  • contact details (address, phone number, email)

  • information about your personal circumstances

  • participation information (e.g. sport and discipline you compete in, organisations and/or sports federations to which you belong, current level of competition, events, relationships with coaches and medical professionals)

  • athlete movements (training, competitions, travel, time at home, vacation, any other regular or exceptional activities)

  • information related to sport integrity issues (e.g. complaints and reports)

  • information collected during hearings and appeals

  • photographs, video recordings, and audio recordings

  • medical history (as it relates to accident, injury or illness) 

  • passport details (for travel purposes) 

Additionally, may collect and hold Personal Information in relation to employees, job applicants, contractors and others in relation to employment. The personal and sensitive information may include:

  • employment history 

  • CVs

  • qualifications 

  • travel records

  • work health and safety matters including accident and injury records, compensation and rehabilitation files

Sensitive Information

Sensitive information is a type of Personal Information that also includes information or opinion. ISSM may collect sensitive information with consent and in accordance with the Privacy Act. Sensitive information if collected and if relevant, may include:

  • racial or ethnic origin

  • political opinions

  • membership of a political association, professional or trade association or trade union

  • religious beliefs or affiliations or philosophical beliefs

  • sexual preferences or practices

  • criminal record

  • health, genetic information or disability

ISSM obtains consent when collecting sensitive information and will assume your consent to use sensitive information provided to ISSM in accordance with this Policy, unless notified otherwise.

CHILDREN AND YOUNG PEOPLE

ISSM may be required to collect Personal Information concerning children or young persons as party of its services, either directly or through a parent, guardian, coach, mentor or agent. ISSM protects Personal Information irrespective of the source, age and consent.  

HOW DOES ISSM COLLECT PERSONAL AND SENSITIVE INFORMATION?

ISSM collects Personal Information that may be provided by email, telephone, or through social media, face-to-face meetings, events or surveys, online systems, or third parties. ISSM also monitors news and social media.

ISSM will assume that you consent to the use of non-sensitive Personal Information for marketing purposes and sharing such information with service providers. If you do not want to receive email or SMS offers, you may opt-out by providing email to the ISSM Privacy Officer or using the opt-out option in communications from ISSM.

PROVIDING INFORMATION 

ISSM may use and share your Personal Information only for the primary purpose for which it was collected, subject to exceptions. ISSM may also use and share your Personal Information if you provide or imply consent or if it is required by law or enforced by the enforcement body. 

When sharing your Personal Information with third-party service providers, ISSM enters into a confidentiality agreement, which requires that the information is handled securely and not used or disclosed for any other purpose. In certain circumstances, Personal Information may be shared outside of Australia, and ISSM will undertake best efforts to ensure that the information is subject to adequate protection.

INFORMATION STORAGE AND PROTECTION

ISSM stores information in various forms, including in paper and electronic format. Much of the information ISSM collects from and about you, is hosted by a third party data storage provider. 

Security of Personal Information is important to ISSM.  ISSM has taken steps to protect the information we hold from misuse, loss, unauthorised access, modification or disclosure. Some of the security measures ISSM uses includes strict confidentiality requirements of its employees, volunteers and third party contractors, as well as security measures for system access, and security measures for our website such as firewalls and system encryption.

Should a data breach arise that could result in serious harm, ISSM will take proactive steps and measures including notification to the affected individuals(s) and relevant authorities and bodies, detailing the necessary remedial steps. 

HOW DOES ISSM USE AND DISCLOSE PERSONAL AND SENSITIVE INFORMATION?

ISSM may use and disclose your Personal Information for the primary purpose for which it was collected (i.e. providing services, including communicating with you). 

ISSM may use or disclose Personal Information for secondary purposes in the circumstances where: 

  • you expressly or impliedly consent

  • you reasonably expect ISSM to use or disclose the Personal Information for another purpose and it is directly or indirectly related to the services provided and the purpose for which the Personal Information (or sensitive information) was provided to ISSM

  • ISSM is required to provide the Personal Information by law, including any regulation or order of a court

  • ISSM reasonably believes that the use or disclosure of the Personal Information is necessary

Use

ISSM relies upon third party service providers such as website developers and marketing teams. ISSM provides Personal Information to these third parties to assist ISSM facilitate, perform and deliver services to you. 

In protecting Personal Information disclosed to third parties, ISSM will enter into a confidentiality agreement which requires that services provider to only use or disclose the information in accordance with that confidentiality agreement, which includes special provision(s) to ensure that your Personal Information is handled securely. Any third party is not permitted to use or disclose any Personal Information given to them for any other purpose. 

Disclosure

In some circumstances, Personal Information may also be disclosed outside of Australia. In such circumstances, ISSM will use its best endeavours to ensure such parties are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are suitably similar to the APP.

Any disclosure will be on such terms and conditions as ISSM determines taking into account the circumstances of the disclosure but always with your best interests.

DIRECT MARKETING

ISSM will assume consent to use of non-sensitive Personal Information to provide to you better services and marketing purposes (including disclosure of such information to service providers).

Every person whose data is collected by ISSM has the option to refuse e-mail, SMS or posted offers. You may do this by email providing an email to the ISSM Privacy Officer (details below) or through the opt-out procedures included in any communication from ISSM.

ISSM WEBSITE

When users visit the ISSM website, our systems may record certain information about the use of the site, including the web pages visited and the time and date of their visit. ISSM uses this information to help analyse and improve the performance of the ISSM website.

ISSM will treat this information in the same way as other Personal Information collected. You are free to disable cookies on your internet browser.

ISSM values the trust placed in it and respects this trust and uses commercially acceptable means to protect Personal Information however, no transmission over the internet, or means of electronic storage, is entirely secure and reliable, accordingly, ISSM cannot guarantee absolute security.

LINKS TO OTHER SITES

ISSM’s website or services provided, may direct you to third party websites. Third party sites are not operated by ISSM and ISSM assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. Linked third party or external websites are not subject to ISSM’s privacy standards, policies or procedures. 

ISSM strongly recommends you review the privacy policies of any third party websites.

ACCESSING AND SEEKING CORRECTION OF INFORMATION HELD BY ISSM

ISSM will take all reasonable steps to ensure that the Personal Information it collects, uses or discloses is accurate, complete and up-to-date. However, ISSM relies upon the accuracy of Personal Information provided to ISSM, directly and indirectly.

We require you to keep ISSM updated about any changes to Personal Information provided.

You have the right to ask for access to the Personal Information ISSM holds about you and if there is any error in that Personal Information, the right to ask that ISSM correct that Personal Information in accordance with the relevant provisions of the Privacy Act. 

UPDATING THIS POLICY

ISSM may update this Policy periodically. You will be notified of any update to this Policy by ISSM posting an updated version to the ISSM website. ISSM recommends you to check the ISSM website from time to time for any changes, which are effective upon posting. 

RESOLVING PRIVACY ISSUES AND COMPLAINTS 

Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to your Personal Information may be made to the ISSM Privacy Officer at this address:

ISSM Privacy Officer 

Email: info@innersanctumsportsmgt.com.au
Phone: 0401 690 893

We will respond and endeavour to resolve any complaint within thirty (30) days of written notice. If we are unable to resolve your complaint within this time, or you are unhappy with the outcome, you can contact the Office of Australian Information Commissioner through its enquiries line 1300 363 992 or website www.oaic.gov.au

For further information on ISSM’s management of Personal Information, please contact ISSM.

POLICY RECORD

Policy Owner: COO

Endorsed By: Nicole Comerford, Director and Clare Starling, Director

Date Endorsed: 13 July 2024

Date Last Reviewed: 13 July 2024

Next Review Date: 13 July 2025